(about the switch-over clause in the ATA Directive)
In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence…
On 28 January 2016, the European Commission issued its proposal for a Council Directive dealing with tax avoidance practices within the EU – the so-called Anti-BEPS Directive. The context of the…
I. Introduction
Shall international tax planning decrease after the implementation of BEPS? The reply is "depends" by virtue of the subject’s exposure to several variables.
Obviously, one should…
The IRS issued Notice 16-08 announcing that it will extend timelines or modify four elements of FATCA -
(1) modify the date for submitting to the IRS the preexisting account certifications required…
In 2015, people around the globe celebrated the 800th anniversary of the Magna Carta Libertatum, considered to be the first constitutional-like document that established restrictions on a sovereign’s…
The Indian Ministry of Finance released last month draft guidance on applying the “place of effective management” (POEM) test to determine tax residence of companies. The guidance came almost eight…
On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our friends at Wolters Kluwer (a…
Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…
Volume 44 (2016) Issue 1 contains:
EDITORIAL
Ana Paulo DOURADO, 'May You Live In Interesting Times'
Abstract: In the current global tax good governance context, exchange of information is one…
In his last State of the Union speech on January 13, 2016 Obama put it quite clear: “The United States of America is the most powerful nation on Earth. Period. It's not even close.”
With this…
